Privacy Policy

Kestral and Your Privacy

Kestral Computing Pty Ltd is a part of the global
Jonas Software group. As such, we adhere to the privacy
policy set forth by Gary Jonas Computing Ltd. for its
subsidiaries worldwide. This policy is outlined here in
detail.

Privacy Policy

Gary Jonas Computing Ltd. and its worldwide
subsidiaries and affiliates that comprise the Jonas
Family of Companies (“Jonas,” “we,” “us,” ”our”) are
committed to protecting your privacy. There are various
ways that you might interact with Jonas, and the
information you provide when doing so allows us to
improve our services. By using this website and our
related websites (collectively, the “Site”) and by
supplying your details to Jonas, you consent to Jonas
collecting and processing your information.

Our privacy policy explains:

What information we collect, and why we
collect it;

How we use that information;

How we protect that information;

How you can control your information, including
accessing, updating and deleting what we store; and

How we share information collected.

Compliance

Jonas adheres to Canadian and international statutes
and regulations which govern the protection of personal
information. In Canada, Jonas adheres to the Personal
Information and Protection of Electronic Documents Act
(“PIPEDA”). In the United States, Jonas adheres to
statutes of general application and statutes of specific
application such as the Health Insurance Portability and
Accountability Act (“HIPPA”) where applicable. In
Australia, Jonas complies with the Privacy Act, 1988, a
federal statute, as well as with State and Territory
laws pertaining to protection of personal information;
including the Health Records Act 2001(VIC) where
applicable. In New Zealand, Jonas follows the Privacy
Act, 1993. In Europe, Jonas adheres to the Data
Protection Act, 1998, the European Union ("EU") Data
Protection (95/46/EC) and ePrivacy (2002/58/ED)
Directives (as transposed into national law), the EU
Privacy Directive dated May 26, 2012 (regarding cookies
and other matters) and registers annually with the
Information Commissioner’s Office.

Information We Collect & Share

We may collect or record basic personal information
(e.g., name, email address, mailing address, phone
number) which you voluntarily provide through forms on
our Site, through electronic mail you send to us, or
through other means of communication between you and us.

We only collect personal information of a more
sensitive nature (e.g. social security or other
governmental ID numbers, credit card details and account
numbers) where it is appropriate or necessary for
conducting business. This information will be collected,
stored, accessed and processed in a secure manner. We
may also collect general non-personal information
pertaining to users of our sites, including IP
addresses, source domain names, specific web pages,
length of time spent and pages accessed. This
information is collected, among other things, to
aggregate statistical information, facilitate system
administration and improve the Site. We recognize and
have controls in place to ensure that the privacy of
personal information about an identifiable individual
used in the course of commercial activity is protected
and managed.

We also collect, use and disclose identifiable
information about individual contacts for our customers
(“Business Contact Information”) in the ordinary course
of our business for managing and maintaining customer
relationships. In particular, we may obtain the
following types of Business Contact Information: name,
address, invoice information (including bank account
information), and order information. Unless otherwise
specified or prohibited, we may share information with
affiliates, business partners, service providers,
subsidiaries or contractors who are required to provide
you with services which you have requested from us.

We may also post links to third party websites as a
service to you. These third party websites are operated
by companies that are outside of our control and your
activities at those third party websites will be
governed by the policies and practices of those third
parties. We encourage you to review the privacy policies
of these third parties before disclosing any
information, as we are not responsible for the privacy
policies of those websites.

How We Use Information

We use the information we collect to provide you with
services which you request and to improve our existing
services and the content of our Site. When you contact
us, we may keep a record of your communication to help
solve any issues that you might be facing. Your
information may be retained for a reasonable time for
use in future contact with you, or for future
improvements to our services. You have the option to
opt-out or opt-in for further communications from us.

We may also use or disclose your personal information
when we believe, in good faith, that such use or
disclosure is reasonably necessary to (i) comply with
law, (ii) enforce or apply the terms of any of our user
agreements, or (iii) protect our rights, property or
safety, or the rights, property or safety of our users,
or others. We reserve the right to transfer and disclose
your information if we become involved in a business
divestiture, change of control, sale, merger, or
acquisition of all or a part of our business.

In certain cases, we also operate as an information
processor for our business customers. Our business
customers remain the information controllers with
respect to any customer information that they provide to
us for our provision of services. We therefore act in
accordance with the instructions of such customers
regarding the collection, processing, storage, deletion
and transfer of customer information, as well as other
matters such as the provision of access to and
rectification of customer information.

We do not sell our services to children. As such, our
Sites are designed for adult user interaction. We do not
intentionally collect personally identifiable
information from children under the age of 13.

Cookies are a technology that can be used to help
personalize your use of a website. A cookie is an
element of information that a website can send to your
browser, which may then store it on your system. You can
set your browser to notify you when you receive a
cookie, giving you the chance to decide whether to
accept it or decline at any time. To enable us to assess
the effectiveness and usefulness of this Site, and to
give you the best user experience, we collect and store
information such as pages viewed by you, your domain
names and similar information. Our Site makes use of
anonymous cookies for the purposes of:

Completion and
support of Site activity;

Site and
system administration;

Research and
development; and

Anonymous user
analysis, user profiling, and decision-making.

An Internet Protocol (“IP”) address is associated with
your computer’s connection to the internet. We may use
your IP address to help diagnose problems with our server,
to administer the Site and to maintain contact with you as
you navigate through the Site. Your computer’s IP address
also may be used to provide you with information based
upon your navigation through the Site.

Aggregate information is used to measure the
visitors’ interest in, and use of, various areas of the
Site and the various programs that we administer. We
will rely upon aggregate information, which is
information that does not identify you, such as
statistical and navigational information. With this
aggregate information, we may undertake statistical and
other summary analyses of the visitors’ behaviors and
characteristics. Although we may share this aggregate
information with third parties, none of this information
will allow anyone to identify you, or to determine
anything else personal about you.

Collection and Use of Employee Personal Information

We also collect personal information from our
employees and from job applicants (human resource data)
in connection with administration of our human resources
programs and functions. These programs and functions
include, but are not limited to: job applications and
hiring programs, compensation and benefit programs,
performance appraisals, training, access to our
facilities and computer networks, employee profiles,
employee directories, human resource recordkeeping and
other employment related purposes. It is our policy to
keep all past and present employee information private
from disclosure to third parties. There are certain
business related exceptions and they are:

To comply with municipal, regional, provincial
or federal agency requests;

Inquiries from third parties with a signed
authorization from the employee to release the
information, except in situations where limited
verbal verifications are acceptable (see below);

Third parties with which we have contractual
agreements to assist in administration of company
sponsored benefits.

Prospective employers, government agencies, financial
institutions and residential property managers routinely
contact us requesting information on a former or current
employee’s work history and salary. All such requests of
this type shall be referred to and completed on a
confidential basis by the human resources department or
payroll department. For written verification of
employment requests, information will be provided on the
form only when it is accompanied by an employee’s signed
authorization to release information. The form will be
returned directly to the requesting party and filed as
part of the human resources or payroll department’s
confidential records.

Security

The security of your personal information is
important to us. We follow generally accepted industry
standards to protect the personal information submitted
to us, both during transmission and once we receive it.

We use reasonable measures to safeguard personally
identifiable information; which measures are appropriate
to the type of information maintained and follow
applicable laws regarding the safeguarding of any such
information under our control. In addition, in some
areas of our Sites, we may use encryption technology to
enhance information privacy and help prevent loss,
misuse or alteration of the information under our
control. We also employ industry-standard measures and
processes for detecting and responding to inappropriate
attempts to breach our systems.

No method of transmission over the Internet, or
method of electronic storage, can be 100% secure.
Therefore, we cannot guarantee the absolute security of
your information. The Internet by its nature is a public
forum and we encourage you to use caution when
disclosing information online. Often, you are in the
best situation to protect yourself online. You are
responsible for protecting your username and password
from third party access and for selecting passwords that
are secure.

Monitoring and Enforcement

We regularly review our compliance with our privacy
policy. We also adhere to several self-regulatory
frameworks in addition to complying with applicable law.
If we receive formal written complaints, we will follow
up with the person making the complaint. We work with
the appropriate regulatory authorities to resolve any
complaints that cannot be resolved directly.

Accessing and Updating Your Personal Information

If you have provided us with your personal
information, you may have the right to inspect the
information stored by us for accuracy, or may request
that the information be removed from our files. We will
make a reasonable effort to comply with such requests
except where it would require a disproportionate effort
(for example developing a new system or changing an
existing practice). We may require that you verify your
identity before we act on a request to edit or remove
your information. Please direct any questions about your
information to the Privacy Contact identified below to
review any personal information held about you.

Social Media and Online Engagement

We occasionally use a variety of new technologies and
social media options to communicate and interact with
customers, potential customers, employees and potential
employees. These sites and applications include popular
social networking and media sites, open source software
communities and more. To better engage the public in
ongoing dialog, certain of our businesses use certain
third-party platforms including, but not limited to,
Facebook, Twitter and LinkedIn. Third-Party Websites and
Applications (TPWA) are Web-based technologies that are
not exclusively operated or controlled by us. When
interacting on those websites, you may reveal certain
personal information to us or to third parties. Other
than when used by our employees for the purpose of
responding to a specific message or request, we will not
use, share, or retain your personal information.

Changes to this Privacy Policy

We may change this privacy policy from time to time.
If this privacy policy changes, the revised privacy
policy will be posted at the "Privacy Policy” link on
the Site’s home page. In the event that the change is
significant or material, we will notify you of such a
change by revising the link on the home page to read
"Newly Revised Privacy Policy." Please check the privacy
policy frequently. Your continued use of the Site
constitutes acceptance of such changes in the privacy
policy, except where further steps are required by
applicable law. This privacy policy was last updated on
the date set out at the end of the policy.